In re Richard M.

Summary

The Maine Supreme Judicial Court affirmed a District Court judgment terminating the parental rights of Richard M.’s mother and father. The court held that competent evidence supported findings of parental unfitness and that termination, with adoption as the permanency plan, was in the child’s best interest.

Holdings

1. Competent record evidence supported each of the three statutory bases for parental unfitness found by the District Court, including failure to take responsibility, inability or unwillingness to protect the child from jeopardy within a time reasonably calculated to meet his needs, and failure to make a good-faith effort toward reunification.
2. The District Court properly linked the parents' parenting deficiencies to specific risks of harm to Richard M.; the lack of a sexual-abuse conviction and the legal status of recreational marijuana did not negate the risks identified by the court.
3. The District Court did not abuse its discretion in determining that termination of the mother's and father's parental rights, with a permanency plan of adoption, was in the child's best interest.

Questions Presented

1. Whether competent evidence supported the District Court's findings of parental unfitness under 22 M.R.S. § 4055.
2. Whether the District Court abused its discretion in determining that termination of both parents' parental rights was in Richard M.'s best interest.
3. Whether the District Court sufficiently linked the parents' parenting deficiencies to specific risks of harm to the child.

Disposition

affirmed